Alexandria U.S. District Court Anthony Trenga said the Supreme Court of Virginia has not decided whether “reasonable notice” means “advance” notice, and state and federal courts have differed on interpretations of “reasonable notice.”

Under Virginia law, the judge wrote, “’reasonable notice’ requires that the manner and quality of the notice of termination must effectively communicate the fact of the termination.”

To require advance notice “would impose restrictions on at-will employment that contradict the very nature of the at-will doctrine,” the judge said in his Sept. 11 decision in Calquin v. Doodycalls Fairfax VA Inc.

In Calquin’s case, a directive that he “leave the premises” met the reasonable notice test.
By Deborah Elkins